ATO Template Manuals
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With the importance of the change from RTF to ATO, if they use the minimal time available to bang on about infringements, I will walk out.
I'm loosing a days income to attend.
If they want to stop infringements I would be better off spending any cash or fees on supplying moving map gps for customer use.
I'm loosing a days income to attend.
If they want to stop infringements I would be better off spending any cash or fees on supplying moving map gps for customer use.
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ATO TRANSITION SEMINAR
Attended the CAA Seminar at Gatwick today. It was well organised and presented, and in fairness to the CAA staff that were in attendance they worked hard to deal with the many questions raised. So credit where credit is due.
The much awaited ATO template manuals were distributed on CD (together with other info and seminar presentation notes). The template manual runs to some 79 pages, and to complete it will require a good deal of thinking and time; I suspect the finished product could easily double or treble in size, and like any proformae document it is difficult to get a one size fits all. Anyway, I think its a step in the right direction,and we will have to see how it plays out when submitted for approval.
The much awaited ATO template manuals were distributed on CD (together with other info and seminar presentation notes). The template manual runs to some 79 pages, and to complete it will require a good deal of thinking and time; I suspect the finished product could easily double or treble in size, and like any proformae document it is difficult to get a one size fits all. Anyway, I think its a step in the right direction,and we will have to see how it plays out when submitted for approval.
I have a copy of the template ATO Manual
On initial reading, it contains three worrying developments:
PPL TK study requirement
Early on in the document, AMC FCL.210; FCL.215 is correctly quoted with reference to the 100 hours theoretical knowledge requirement for the PPL course, stating '... the theoretical knowledge instruction should include a certain element of formal classroom work.'
Fine. However, on page 77 of 79 there is the following statement: 'CAA policy is that no more than 33% of the total instructional time may be devoted to computer based training and other media distance learning courses... self-study may be acceptable as an 'other media distance learning course'.
In other words, 67 hours of the 100 hour TK requirement must be conducted in a classroom because 'CAA policy' says so.
Who came up with this policy? What is the safety case for the introduction of the policy? When was the Regulatory Impact Assessment carried out for this new policy and what were the findings?
The minimum classroom requirement for ATPL TK is 10% (65 hours out of 650). Why is it 67% (67 hours out of 100) for private pilots?
67 hours of classroom work will add approximately £1700 to the cost of a PPL.
---------
Aircraft MEL
If your training aircraft is fitted with a transponder but it is inoperative then no solo student flying is permitted, even if it's just circuit work.
---------
Exam invigilators
All students sitting PPL exams will have to be overseen by an invigilator. Another cost for the school, and ultimately the student.
---------
Anyone attending the CAA RTF-ATO roadshow tomorrow (Weds 13 Nov) at Sywell might like to ask the Authority why it is apparently continuing to gold-plate EASA AMCs despite multiple assurances from CAA CEO Andrew Haines that "there will be no more gold-plating of regulations".
Additionally, roadshow attendees might like to ask how this overblown manual and its attendant gold-plating regime sits with Minister without Portfolio Grant Schapps. In a recent statement concerning the GA Red Tape Challenge he said:
"We have identified a number of areas where existing regulations are unduly onerous, or where the CAA could improve its approach. The measures we are announcing today (6 November 2013) will ensure that the regulatory framework is proportionate - deregulating completely wherever possible, and minimising regulation where it is still necessary."
In the same press release, Aviation Minister Robert Goodwill stated:
"...making sure that, where appropriate, we ease the burden on what are often smaller operators and businesses who find navigating a complex regulatory framework particularly challenging."
On initial reading, it contains three worrying developments:
PPL TK study requirement
Early on in the document, AMC FCL.210; FCL.215 is correctly quoted with reference to the 100 hours theoretical knowledge requirement for the PPL course, stating '... the theoretical knowledge instruction should include a certain element of formal classroom work.'
Fine. However, on page 77 of 79 there is the following statement: 'CAA policy is that no more than 33% of the total instructional time may be devoted to computer based training and other media distance learning courses... self-study may be acceptable as an 'other media distance learning course'.
In other words, 67 hours of the 100 hour TK requirement must be conducted in a classroom because 'CAA policy' says so.
Who came up with this policy? What is the safety case for the introduction of the policy? When was the Regulatory Impact Assessment carried out for this new policy and what were the findings?
The minimum classroom requirement for ATPL TK is 10% (65 hours out of 650). Why is it 67% (67 hours out of 100) for private pilots?
67 hours of classroom work will add approximately £1700 to the cost of a PPL.
---------
Aircraft MEL
If your training aircraft is fitted with a transponder but it is inoperative then no solo student flying is permitted, even if it's just circuit work.
---------
Exam invigilators
All students sitting PPL exams will have to be overseen by an invigilator. Another cost for the school, and ultimately the student.
---------
Anyone attending the CAA RTF-ATO roadshow tomorrow (Weds 13 Nov) at Sywell might like to ask the Authority why it is apparently continuing to gold-plate EASA AMCs despite multiple assurances from CAA CEO Andrew Haines that "there will be no more gold-plating of regulations".
Additionally, roadshow attendees might like to ask how this overblown manual and its attendant gold-plating regime sits with Minister without Portfolio Grant Schapps. In a recent statement concerning the GA Red Tape Challenge he said:
"We have identified a number of areas where existing regulations are unduly onerous, or where the CAA could improve its approach. The measures we are announcing today (6 November 2013) will ensure that the regulatory framework is proportionate - deregulating completely wherever possible, and minimising regulation where it is still necessary."
In the same press release, Aviation Minister Robert Goodwill stated:
"...making sure that, where appropriate, we ease the burden on what are often smaller operators and businesses who find navigating a complex regulatory framework particularly challenging."
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OK in order hopefully.....
The TK 30hrs is something the CAA are trying to 'recommend' with no legal grounding. I discussed this at a recent audit and told them that we would be sticking with 10hrs until such time as it was proven ineffective. They accepted this.
You are incorrect on the MEL, it only applies if you put it in the manual. It does not have to be in the manual. If you don't like it don't use that bit. The manuals are a guide not the law...
Exam invigilators. There has always been a requirement for the exam to be invigilated!! This does not mean someone sat in the room with the student, it could be the GRE in the next room, the receptionist or an FI ensuring that the student does not cheat. This means ensuring that they only enter the exam room with the required materials for the paper and nothing else in the room that might be used to cheat.
The requirement is for the GRE to issue and collect/mark the paper so its actually no change from the old system.
The TK 30hrs is something the CAA are trying to 'recommend' with no legal grounding. I discussed this at a recent audit and told them that we would be sticking with 10hrs until such time as it was proven ineffective. They accepted this.
You are incorrect on the MEL, it only applies if you put it in the manual. It does not have to be in the manual. If you don't like it don't use that bit. The manuals are a guide not the law...
Exam invigilators. There has always been a requirement for the exam to be invigilated!! This does not mean someone sat in the room with the student, it could be the GRE in the next room, the receptionist or an FI ensuring that the student does not cheat. This means ensuring that they only enter the exam room with the required materials for the paper and nothing else in the room that might be used to cheat.
The requirement is for the GRE to issue and collect/mark the paper so its actually no change from the old system.
That all sounds very sensible, Bose.
However, while your ATO approval may have worked along those lines, the template manual differs:
At the beginning of the template manual it offers completion guidance, stating that text shown in blue is for guidance, text shown in red is where an ATO will need to provide their own specific information, and that where it is "required for the ATO to show its compliance" the text is written in black.
The CAA policy statement on 67 hours minimum TK classroom study is written in black.
MEL - Agreed, I hadn't spotted the non-mandatory elements. However, it should be noted that if the aircraft is also used for commercial air transport then the enforced MEL and limitations, in entirety, also apply to flight training.
Exam invigilators - The text (in black, i.e. mandatory according to the intro blurb) states: "The examination will be completed under the supervision of a Ground Examiner approved by the competent authority for the purpose. Candidates are not to be left alone in the examination room whilst the examination is in progress."
While the individual(s) who processed your ATO approval appear to have exercised restraint and common sense, the individual(s) who wrote the template manual appear to have a different agenda.
However, while your ATO approval may have worked along those lines, the template manual differs:
At the beginning of the template manual it offers completion guidance, stating that text shown in blue is for guidance, text shown in red is where an ATO will need to provide their own specific information, and that where it is "required for the ATO to show its compliance" the text is written in black.
The CAA policy statement on 67 hours minimum TK classroom study is written in black.
MEL - Agreed, I hadn't spotted the non-mandatory elements. However, it should be noted that if the aircraft is also used for commercial air transport then the enforced MEL and limitations, in entirety, also apply to flight training.
Exam invigilators - The text (in black, i.e. mandatory according to the intro blurb) states: "The examination will be completed under the supervision of a Ground Examiner approved by the competent authority for the purpose. Candidates are not to be left alone in the examination room whilst the examination is in progress."
While the individual(s) who processed your ATO approval appear to have exercised restraint and common sense, the individual(s) who wrote the template manual appear to have a different agenda.
Bose, it's all very well to say 'do your own' but there are plenty of schools who don't have the time or resources to create their own manuals and who have been relying on the release of a template manual to assist in their conversions.
If they now deviate from filling in the template manual exactly as the CAA have stipulated, including conformity with these new gold-plated policies, they will presumably have their applications rejected, exposing themselves to additional approval costs amounting to £170 per hour.
And if they do conform they will have to increase their PPL course fees by £1,700 to offset the 67 hours classroom requirement, and charge additional sums to pay for a ground examiner to sit in a room while his/her student sits their TK tests.
If they now deviate from filling in the template manual exactly as the CAA have stipulated, including conformity with these new gold-plated policies, they will presumably have their applications rejected, exposing themselves to additional approval costs amounting to £170 per hour.
And if they do conform they will have to increase their PPL course fees by £1,700 to offset the 67 hours classroom requirement, and charge additional sums to pay for a ground examiner to sit in a room while his/her student sits their TK tests.
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And if they do conform they will have to increase their PPL course fees by £1,700 to offset the 67 hours classroom requirement, and charge additional sums to pay for a ground examiner to sit in a room while his/her student sits their TK tests.
Here is what we did.....
Chose an online CBT provider for the PPL TK. Entered into a deal with the to provide the training which we obviously make a margin out of. Use the time tracking function of the provider to track 90hrs of self study. Then told the CAA that we are going to provide 10hrs of classroom training.
Accepted by the CAA.
The stuff in the manuals is not LAW it is guidance, even in the template manuals you do not have to follow to the letter what is in them, you can deviate if you can provide a simple clear statement that covers the requirements.
There is NO requirement for anyone to sit in the room with the student. The invigilator can be outside the exam room doing other things provided that they can ensure the student is not cheating. This has not changed. Therefore there is no need for you to pay anyone to sit with the student.
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Bose thank you for sharing you experiences
"Chose an on-line CBT provider for the PPL TK. Entered into a deal with the to provide the training which we obviously make a margin out of"
Doesn't this add to the total cost of a PPL with your organisation? Yet as in industry we compete world wide for flight training. Hasn't this just made flight training in UK/EU less competitive against flight training in the USA?
"Chose an on-line CBT provider for the PPL TK. Entered into a deal with the to provide the training which we obviously make a margin out of"
Doesn't this add to the total cost of a PPL with your organisation? Yet as in industry we compete world wide for flight training. Hasn't this just made flight training in UK/EU less competitive against flight training in the USA?
A few errors from the CAA, it seems...
Firstly, there is NO mandatory LAPL groundschool requirement, even though the exams are the same.
Also, in the draft Training Manual, the author which was 'Aynho Aviation', the following wording had been crossed out:
Firstly, there is NO mandatory LAPL groundschool requirement, even though the exams are the same.
Also, in the draft Training Manual, the author which was 'Aynho Aviation', the following wording had been crossed out:
• It is established CAA policy that the proportion of a course conducted as distance learning does not exceed 33% of the total hours required. Consequently at least 66 hours must be programmed as formal classroom instruction.
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A question with the template ATO manuals:
From time to time we get people don't have a SEP rating. Usually CPL/MEP holders. Do the template manuals give approval to allow us to train for this.
They don't include Night Training - Why is this. Seems a bit of an over sight?
From time to time we get people don't have a SEP rating. Usually CPL/MEP holders. Do the template manuals give approval to allow us to train for this.
They don't include Night Training - Why is this. Seems a bit of an over sight?
Last edited by Mickey Kaye; 12th Nov 2013 at 21:23.
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I think there is a communications issue here. Those of us who have dealt with the CAA as FTOs and/or AOC holders are used to having a two way dialogue with our TIs and FOIs. Consequently, we are content with bashing around concepts and ides when developing manuals.
Conversely, the conversion of RFs to ATOs will inevitably be the first real exposure many people will have beyond the old system of firing in a load of application and registration forms. The are used to clear regulation and generally accept the CAA's own interpretation of such regulation rather than offer their own means of compliance.
Maybe it would be worth RFs being allocated a specific TI who could then help to build that relationship? Of course, the word is that there are a severe lack of TIs.
Mickey, you will need specific approval for both. For example, the MEP to SEP route would require you to define a class rating 'course'. Not complex, just make sure you list all the approvals you think you will need on your initial application and then talk through with your TI or a friendly flying school.
Conversely, the conversion of RFs to ATOs will inevitably be the first real exposure many people will have beyond the old system of firing in a load of application and registration forms. The are used to clear regulation and generally accept the CAA's own interpretation of such regulation rather than offer their own means of compliance.
Maybe it would be worth RFs being allocated a specific TI who could then help to build that relationship? Of course, the word is that there are a severe lack of TIs.
Mickey, you will need specific approval for both. For example, the MEP to SEP route would require you to define a class rating 'course'. Not complex, just make sure you list all the approvals you think you will need on your initial application and then talk through with your TI or a friendly flying school.
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"For example, the MEP to SEP route would require you to define a class rating 'course"
And that's why this gets a bit hazy. I can teach someone from scratch to fly a SEP but if someone comes along and wants add an SEP rating then (unless we submit a wodge of paperwork) we can't.
Is it just me or does that seem a bit unnecessary?
And that's why this gets a bit hazy. I can teach someone from scratch to fly a SEP but if someone comes along and wants add an SEP rating then (unless we submit a wodge of paperwork) we can't.
Is it just me or does that seem a bit unnecessary?
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Mickey Kaye
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A question with the template ATO manuals:
From time to time we get people don't have a SEP rating. Usually CPL/MEP. Do the template manuals give approval to allow us to train for this.
They don't include Night Training - Why is this. Seems a bit of an over sight?
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A question with the template ATO manuals:
From time to time we get people don't have a SEP rating. Usually CPL/MEP. Do the template manuals give approval to allow us to train for this.
They don't include Night Training - Why is this. Seems a bit of an over sight?
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Again that's why in my eyes its gets hazy.
At present every rf is allowed to offer SEP class rating courses and night ratings. Hence I think it should of been part of the template manuals.
At present every rf is allowed to offer SEP class rating courses and night ratings. Hence I think it should of been part of the template manuals.